In a notice published in the Federal Register earlier this week, the Commodity Futures Trading Commission (“CFTC”) again reopened the period to comment on its proposed position limits and aggregation rules, in light of questions posed at an Agricultural Advisory Committee meeting in December.  The CFTC’s proposed rules, which we summarized here when they were first issued, would set position limits for 28 physical commodity contracts and economically equivalent swaps, including four energy contracts:  (1) NYMEX Henry Hub Natural Gas (NG); (2) NYMEX Light Sweet Crude Oil (CL); (3) NYMEX RBOB Gasoline (RB); and (4) NYMEX NY Harbor ULSD (HO).  The reopened comment period will close on January 22, 2015.

Tags: CFTC, commodity derivatives, crude oil, natural gas, Position Limits
Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Photo of Mark D. Herman Mark D. Herman

Mark Herman advises companies on insurance coverage and represents them in coverage litigation against their insurers.

Mark has helped clients recover hundreds of millions of dollars for a wide variety of losses and liabilities, including products liability and mass tort litigation, securities litigation…

Mark Herman advises companies on insurance coverage and represents them in coverage litigation against their insurers.

Mark has helped clients recover hundreds of millions of dollars for a wide variety of losses and liabilities, including products liability and mass tort litigation, securities litigation, professional liability claims, property losses and business interruption, and cyber events. He has also advised clients on aviation, trade credit, political risk, and representation and warranty (R&W) insurance claims. Mark’s clients have included public and private companies in the life sciences, financial services, energy, and aerospace sectors, private equity firms, non-profits, and individuals.

Mark has successfully represented clients in trial and appellate litigation, including arguing and winning motions for summary judgment on key coverage issues. He also helps clients avoid litigation by navigating the insurance claim process and counseling clients in settlement negotiations and mediation. Mark also advises clients on insurance and risk management issues, including policy placements.

For his successful representation of his policyholder clients, Mark has been recognized by Law360 as an “Insurance MVP” and a “Rising Star.” He has also been recognized twice in AmLaw’s “Litigator of the Week” column.

Read more about Mark D. HermanEmail
Show more Show less